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WEBSITE PRIVACY POLICY

Privacy Statement

Effective Date: January 1, 2020.


PRIVACY STATEMENT

Kingsley Associates (“Kingsley”, “we”, or “us”) understands that your privacy is
important to you. Protecting your personal information is our priority. This
Privacy Statement describes how we handle and protect the personal information
that we collect or use in connection with our business activities and customer
services, and on websites, applications, and communications that post a link to
this Privacy Statement. As used in this Privacy Statement, “personal
information” shall be any information that is capable of identifying you as an
individual person.

Summary

 * How We Collect Your Personal Information
 * How We Use Your Personal Information
 * How We Protect Your Personal Information
 * How Long We Retain Your Personal Information
 * How We Share Your Personal Information
 * How We Transfer Personal Information Across International Borders
 * Links To Third Party Websites
 * How We Respect Your Privacy in Marketing
 * Use of Cookies and Other Tracking Technologies on Our Websites
 * Your California Privacy Rights
 * How To Contact Us
 * Children Under Thirteen
 * Changes To This Privacy Statement


HOW WE COLLECT YOUR PERSONAL INFORMATION

We collect information about you from the following sources:

 * Directly from you
 * From technology when you visit our website, applications or other digital
   properties
 * From our clients when they hire us to conduct surveys or benchmarking on
   their behalf


WHAT PERSONAL INFORMATION WE COLLECT

Kingsley may collect some or all of the following personal information:

 * Identifiers, such as your name, email address, mailing address, telephone
   number, and birthdate
 * Demographic information
 * Commercial information, including records of personal property, products or
   services, purchase, obtained, considered or leased, or other purchasing or
   consuming histories or tendencies, provided that for individual survey
   respondents, we do not receive financial information about your lease
 * Identifiers and internet or other online network activity information, such
   as IP address, device identifier, web browser, and browsing and use
   information collected through cookies, web beacons, pixels, clear gifs, and
   other similar technologies (collectively “Cookies and Other Tracking
   Technologies”)
 * Professional or employment-related information
 * Inferences drawn from any of the information identified above

You should be aware that whenever you publicly disclose information online, that
information could be collected and used by others. We are not responsible for
any action or policies of any third parties who collect information that users
publicly disclose in any such forums on the websites.


HOW WE USE YOUR PERSONAL INFORMATION

We collect and use your personal information to:

 * manage stakeholder feedback programs on behalf of our customers (e.g., tenant
   satisfaction surveys, resident satisfaction surveys, employee surveys, broker
   perception surveys)
 * provide products and services to our customers such as benchmarking and
   consulting
 * analyze the performance and functioning of our websites, manage our websites
   and collect analytics about how our websites are used

We may keep any of your personal information on file and use it to contact you
if your owner or management company requests additional services from us.

If you are a business client, we use the personal information that we have
collected from you to market to you.  If you are individual survey respondent,
we do not use the personal information that we have collected on behalf of our
customers to market to you.

We also use de-identified or anonymized information for other purposes.


HOW WE PROTECT YOUR PERSONAL INFORMATION

We have implemented reasonable security procedures and technical and
organizational measures to protect personal information against accidental or
unlawful destruction, loss, disclosure or use. Only authorized Kingsley
personnel and third party service providers are provided access to personal
information, and these employees and service providers are required to treat
this information as confidential. Despite these precautions however, we cannot
guarantee that unauthorized persons will not obtain access to your personal
information.


HOW LONG WE RETAIN YOUR PERSONAL INFORMATION

We may retain your personal information for a period of time consistent with the
original purpose for collection.  For example, we keep your personal information
for no longer than reasonably necessary for use of our products and services and
for a reasonable period of time afterward. We also may retain your personal
information during the period of time needed for us to pursue our legitimate
business interests, conduct audits, comply with our legal obligations, resolve
disputes and enforce our agreements.

When personal information is no longer needed for the purpose it was collected
or processed or to comply with a legal obligation, we securely destroy it.


HOW WE SHARE YOUR PERSONAL INFORMATION

We do not sell, rent or lease our customer lists to third parties.  We do not
sell or otherwise disclose personal information that we collect over our
websites or as otherwise collected in connection with our services, except as
described herein.

We may disclose information about you to the following categories of third
parties or in the following circumstances:

 * With third party service providers who perform services and functions on our
   behalf to support our interactions with you, such as conducting statistical
   analyses, sending you emails or postal mail, and providing you with customer
   support. Additionally, personal information collected on our websites may be
   shared and transferred to our third party service providers that service or
   host our websites;

 

 * With our customers, for examples, we share the information collected in
   response to our surveys or benchmarking efforts with the customer that hired
   us to conduct the survey or benchmarking;
 * If we are required to do so by law or legal process;
 * To law enforcement authorities or other government officials;
 * When we believe disclosure is necessary or appropriate to prevent physical
   harm or financial loss or in connection with an investigation of suspected or
   actual illegal activity;
 * If disclosure is necessary to protect the vital interests of a person;
 * To protect our property, services and legal rights;
 * To prevent fraud against Kingsley, our subsidiaries, affiliates and/or
   business partners;
 * To support auditing, compliance, and corporate governance functions;
 * To comply with any and all applicable laws; or
 * To complete a corporate transaction such as a re-organization, merger, sale,
   joint venture, assignment, or other transfer or disposition of all or any
   portion of our business.

Where required by law, we have put in place legal mechanisms designed to ensure
adequate data protection of your personal information that is processed by
Kingsley’s third party service providers, including the transfer of your
personal information to countries other than the one in which you reside. By
using any of the websites and providing information on any of them, you
voluntarily consent to such trans-border transfer and hosting of such
information.


HOW WE TRANSFER PERSONAL INFORMATION ACROSS INTERNATIONAL BORDERS

Kingsley participates in the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks
(“Privacy Shield”) administered by the U.S. Department of Commerce regarding the
collection, use and retention of personal information from European Union member
countries and Switzerland.  Our participation in the Privacy Shield subjects it
to the investigatory and enforcement power of the Federal Trade Commission.  You
can view a complete list of all Privacy Shield participants, including Kingsley
Associates at https://www.privacyshield.gov/list.

As a Privacy Shield participant, we are committed to and has certified that we
adhere to the Privacy Shield Principles for all personal information received
from the European Union and Switzerland in reliance on the Privacy Shield.  If
there is any conflict between the terms in this Privacy Statement and the
Privacy Shield Principles, the Privacy Shield Principles shall govern.

 * We may share personal information that is subject to the Privacy Shield
   Principles with service providers who collect and host personal information
   in cloud-based environments and who provide services that support the
   business activities that we conduct on behalf of our customers. We may be
   liable under the Privacy Shield if service providers process such personal
   information in a manner inconsistent with the Privacy Shield and we are
   responsible for the event giving rise to the damage.
 * We may disclose personal information received in reliance on the Privacy
   Shield in response to lawful requests by public authorities, including to
   meet national security or law enforcement requirements.
 * European Union or Swiss individuals have the right to request access to
   personal information received by us in reliance on the Privacy Shield, to
   request the ability to correct, amend or delete inaccurate personal
   information, and to exercise choice in limiting our use and disclosure of
   such information.  European Union or Swiss individuals who are interested in
   exercising their right and choice, please contact us at the address, phone
   number or email address below.

Kingsley Associates

229 Peachtree St NE, Suite 1100
Atlanta, Georgia 30303
Attn: AJ Rao

(770) 908-1220

privacy@kingsleyassociates.com



We have further committed to refer unresolved privacy complaints under the
Privacy Shield Principles to an independent dispute resolution mechanism, the
BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If
you do not receive timely acknowledgment of your complaint, or if your complaint
is not satisfactorily addressed, please visit
http://www.bbb.org/EU–privacyshield/for–eu–consumers for more information,
including information about how to file a complaint.

Please note that if your complaint is not resolved through these channels, under
limited circumstances, a binding arbitration option may be available before a
Privacy Shield Panel. We are subject to the investigatory and enforcement powers
of the Federal Trade Commission (FTC).

Link to Third Party Websites

We may provide links to third party websites or information as a service to you.
If you use these links, you will leave our website. Such links do not constitute
or imply our endorsement, sponsorship, or recommendation of the third party, the
third party website, or the information contained therein, and we shall not be
responsible or liable for your use thereof. Such use shall be subject to the
terms of use and privacy policies applicable to those sites.

How We Respect Your Privacy in Marketing

We use various means of communication and tools to market our products and
services. We use commercial marketing email as permitted under applicable law.
If you prefer not to receive future communications from us, you may unsubscribe
by using the “Unsubscribe” or “Opt-out” link in the commercial email or by
contacting us at privacy@kingsleyassociates.com or calling us at (770) 908-1220.

Use of Cookies And Other Tracking Technologies On Our Websites

We collect information, via cookies, web beacons, pixels, tags or other tracking
technologies, such as your Internet Service Provider and IP address, the date
and time you access the website, the pages you have accessed while visiting the
website, and the Internet address from which you accessed the website. We use
these technologies to remember user preferences, analyze and maximize the
performance of our website, applications and services, measure the effectiveness
of our email campaigns and to customize online content.

We do not use cookies for advertising purposes.

You may refuse or delete cookies.  If you refuse or delete cookies, some of our
website functionality may be impaired.  Please refer to your browser’s Help
instructions to learn more about how to manage cookies and the use of other
tracking technologies.

Our websites do not track you by collecting personal information about your
online activities over time and across third party websites or online services.
Accordingly, we do not alter our data collection and use practices in response
to “do not track” signals transmitted from web browsers.

Your California Privacy Rights

We are considered a “data processor”/“service provider” for our customers where
we process personal information to provide our services to our customers. When
we act as a data processor/service provider, we process personal information in
accordance with the instructions of the “data controller”/ “business” (i.e., our
customer).

If you are a California consumer seeking to exercise your rights under the
California Consumer Privacy Act (CCPA) with respect to information we hold on
behalf of our customers, please reach out directly to that organization
responsible for determining the purposes and means of processing your personal
information, generally your owner or management company.

We do not and will not sell your personal information.

We do not share your personal information with third parties for those third
parties’ direct marketing use.

How To Contact Us

If you have any questions or comments about our Privacy Statement, please
contact us at:

Kingsley Associates
229 Peachtree Street NE, Suite 1100
Atlanta, Georgia 30303

(770) 908-1220

privacy@kingsleyassociates.com

Children Under Sixteen

We do not knowingly collect, use, share or sell personal information from
children under the age of 16. If you believe we have done so in error, please
contact us at the address or email above and we will delete the information.


CHANGES TO THIS PRIVACY STATEMENT

We reserve the right to make changes to this Privacy Statement from time to
time. We will alert you to any such changes by updating this Privacy Statement.
If we make material changes to this Privacy Statement that increase our rights
to use personal information that we have previously collected about you, we will
obtain your consent either through an email to your registered email address or
by prominently posting information about the changes on our website.



OUR MISSION

At Kingsley, we strive to be the real estate industry’s leading provider of
actionable business intelligence.



GREENVILLE

300 Executive Center Drive
Suite 201
Greenville, SC 29615

© 2020 Kingsley | A Grace Hill Company | Website Privacy Policy

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 * Home
 * About Us
   * Our Leadership Team
   * The Kingsley Index™
   * Careers
 * Solutions
   * Tenant Surveys
   * Resident Surveys
   * Employee Surveys
   * Client Surveys
   * Investor Surveys
   * Broker Surveys
   * Strategic Consulting
 * Clients
   * Industry Partnerships
   * Testimonials
 * Research & Insights
 * Contact Us



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